Fintech 2026

UNITED ARAB EMIRATES Trends and Developments Contributed by: Arnold Krutilins and Gabrielle Margerison (nee Lowe), White & Case LLP

Recognised crypto tokens A key structural change introduced by the amend - ments is the removal of the DFSA’s prescribed list of “recognised crypto tokens”. Under the previous framework, authorised firms were generally limited to engaging with crypto tokens that had been formally recognised by the DFSA. Under the updated DFSA CTR, authorised firms are responsible for determining whether a crypto token meets the suitability criteria set out in the DFSA’s General Module (GEN). This change aligns the DIFC regime more closely with other global regulatory approaches that place primary responsibility on regulated firms rather than maintain - The amendments to the DFSA CTR also remove previ - ous thresholds and restrictions on DIFC funds invest - ing directly or indirectly in crypto tokens. Under the updated DFSA CTR, funds are permitted to invest directly or indirectly into crypto tokens without thresh - olds and restrictions, subject to suitability assess - ments and the implementation of risk management controls. This enhances flexibility for DIFC-based fund managers seeking exposure to digital assets. Enhanced investor protection and supervisory framework The updated DFSA CTR introduces strengthened con - duct, governance, custody, disclosure and reporting requirements applicable to firms engaging in crypto token activities, enhancing investor protection through improved safeguarding arrangements, transparency and operational controls. These amendments also refine supervisory and reporting expectations to reflect evolving market risks, supporting more proportionate, risk-based oversight while maintaining regulatory vis - ibility over crypto token activities. ing regulator-maintained token whitelists. Greater flexibility for investment funds These amendments reflect increasing regulatory maturity in the DIFC’s digital asset framework and reinforce its position as a regulated hub for fintech firms engaging in crypto-asset, digital investment and token-based financial services.

via social media platforms, blogs, seminars, public appearances, or other communication channels, are captured by the definition. As a result, individuals based in Onshore UAE who publish investment-related content on global plat - forms may fall within the scope of the Finfluencer Resolution, even where the underlying financial prod - uct is issued outside the UAE. Under the Finfluencer Resolution, finfluencers must register with the CMA before providing Financial Recommendations to the public. To be eligible for registration, the applicant must either: (i) be a finan - cial analyst accredited by the CMA (or an equivalent regulatory authority), and independent of any CMA- licensed entity; or (ii) demonstrate sufficient influence and credibility in financial markets. Influence and cred - ibility in financial markets may be established through factors such as maintaining a meaningful audience base of no fewer than 1,000 followers, having at least six months’ experience in the financial or investment field, regularly providing investment-related analysis or recommendations, or having previous financial rec - ommendations cited by recognised third-party media channels. The CMA retains discretions to approve or reject applications and may impose conditions or restrictions. Once registered, finfluencers are subject to ongoing conduct and disclosure obligations. The Finfluencer Resolution represents a significant development in the UAE’s financial regulatory frame - work and reflects a broader global trend toward reg - ulating online investment commentary. It formalises regulatory oversight of social media-based financial recommendations, enhances investor protection and clarifies that individuals providing investment-related content may be subject to regulatory supervision in a manner analogous to traditional financial advisors. Updated DIFC Crypto Regulations On 12 January 2026, the DFSA amended its Crypto Token Regulation (the “DFSA CTR”) to reflect a more principles-based regime, placing greater responsibility on authorised firms whilst maintaining investor protec - tion and supervisory oversight.

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